In an article for Law360, I examined the recent settlement between the U.S. Department of the Treasury’s Office of Foreign Assets Control and the 3M Company for nearly $10 million to resolve apparent violations of U.S. sanctions on Iran.

While not the largest settlement this year, I pointed out that the 3M settlement is important for several reasons, including: “as to the complexity of U.S. sanctions; as to the duration of OFAC enforcement actions; and as to the benefits and potential drawbacks of voluntary disclosure.” In the article, I examined each of these points in further detail.

The full article, “What Can Be Learned From 3M’s Iran Sanctions Settlement,” was published by Law360 on November 3 and is available online.